suerte99 Privacy Policy

This Policy applies to all personal data collected by suerte99 in connection with the operation of its online casino, sports betting, and gaming platform. It covers data collected through: (a) the suerte99 website at suerte99.com; (b) the suerte99 mobile application, where available; (c) any customer support channels, including live chat and email; and (d) any other touchpoint through which you interact with suerte99 as a platform operator.

This Policy does not govern the data practices of third-party game providers, payment processors, or any other external service providers whose own privacy policies and terms apply independently when you interact directly with their services. suerte99 recommends reviewing the privacy documentation of any third-party service you engage with through the platform.

For the purposes of this Policy, "personal data" refers to any information, whether recorded in a material form or not, from which the identity of an individual can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual, as defined under the Philippine Data Privacy Act of 2012.

For the purposes of the Philippine Data Privacy Act of 2012, suerte99 acts as the Personal Information Controller in respect of all personal data collected through the suerte99 platform. As the Personal Information Controller, suerte99 determines the purposes and means of processing your personal data.

suerte99 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy legislation. The DPO can be contacted using the details set out in Section 13 of this Policy. All data subject requests and privacy-related concerns should be directed to the DPO in the first instance.

suerte99 collects personal data from you in the following categories, depending on how you interact with the platform:

suerte99 does not intentionally collect sensitive personal information beyond what is necessary for identity verification and regulatory compliance. Where sensitive information — such as identification documents containing information about nationality, physical characteristics, or financial standing — is collected as part of our Know Your Customer obligations, it is processed strictly for that purpose and retained only as long as required by applicable law.

suerte99 processes your personal data only where a valid legal basis exists under the Philippine Data Privacy Act of 2012. The legal bases upon which suerte99 relies are as follows:

• Contractual Necessity: Processing of identity, contact, financial, and gaming data is necessary for the performance of the contract between you and suerte99, specifically to operate your account, process your transactions, and deliver gaming services;
• Legal Obligation: Certain processing activities — particularly identity verification, transaction monitoring, and record-keeping — are required by applicable Philippine laws and regulations, including anti-money laundering legislation and PAGCOR regulatory requirements;
• Legitimate Interests: suerte99 processes technical and behavioural data based on its legitimate interests in operating a secure, functional, and fraud-free platform, provided that such interests are not overridden by your rights and interests;
• Consent: Where suerte99 processes your personal data for marketing communications or non-essential cookies, we do so on the basis of your explicit consent, which you may withdraw at any time without affecting the lawfulness of processing carried out prior to withdrawal.

suerte99 uses the personal data collected from you for the following specific purposes:

• Account Creation and Management: To register your suerte99 account, verify your identity, maintain your account settings, and manage your relationship with the platform;
• Transaction Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and to maintain accurate financial records of all account activity;
• Gaming Service Delivery: To provide access to casino games, live dealer tables, fishing games, bingo, and sports betting features, and to record game outcomes for dispute resolution purposes;
• Regulatory Compliance: To fulfil suerte99's legal obligations under applicable Philippine law, including PAGCOR regulations, Anti-Money Laundering Act requirements, and data privacy legislation;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct on the platform, and to maintain the integrity of the gaming environment;
• Responsible Gaming: To monitor gaming patterns in accordance with our responsible gaming obligations and to provide appropriate interventions where player behaviour suggests potential problem gambling;
• Customer Support: To respond to your enquiries, resolve complaints, and maintain records of support interactions;
• Platform Improvement: To analyse how players interact with the suerte99 platform and to identify opportunities to improve user experience, performance, and security;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided your explicit consent and subject to your right to opt out at any time.

suerte99 does not sell your personal data to any third party. Your personal information may be shared only in the following limited circumstances, and always subject to appropriate contractual protections:

• Payment Processors: Financial data necessary to process your GCash, PayMaya, BPI, BDO, or Metrobank transactions is shared with the relevant payment service providers solely for transaction execution purposes;
• Game Providers: Technical identifiers (such as anonymised player IDs and session tokens) are shared with licensed game providers (including Pragmatic Play, PG Soft, JILI, and Evolution Gaming) to facilitate game delivery and record game outcomes;
• Identity Verification Services: Where suerte99 engages third-party Know Your Customer (KYC) providers to assist with identity and age verification, relevant identity documents and personal data are shared for that specific purpose only;
• Regulatory and Law Enforcement Authorities: suerte99 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, or courts of competent jurisdiction where required or authorised by Philippine law;
• IT Infrastructure and Security Providers: Personal data is accessible to suerte99's hosting, security monitoring, and IT service providers who process data on suerte99's behalf under binding data processing agreements.

All third parties with whom suerte99 shares personal data are contractually required to maintain appropriate security measures and to process personal data only for the specified purposes outlined in their agreements with suerte99. suerte99 conducts due diligence on all data processors to ensure compliance with applicable data privacy standards.

suerte99 uses cookies and similar tracking technologies to enhance platform functionality, analyse usage patterns, and support fraud prevention efforts. A "cookie" is a small text file placed on your device when you visit suerte99.com.

The types of cookies used on suerte99 include:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without preventing core platform functionality;
• Functional Cookies: Store your preferences such as language settings, display preferences, and responsible gaming tool configurations to improve your experience across sessions;
• Analytics Cookies: Used to understand how players navigate the suerte99 platform — which pages are visited, how long sessions last, and where players encounter issues — to help us improve the platform;
• Security and Fraud Prevention Cookies: Help suerte99 identify and flag unusual account activity, protect against automated bot access, and prevent unauthorised account access.

You may control non-essential cookies through your browser settings or through the suerte99 cookie preference centre. Disabling certain cookies may affect the functionality of parts of the platform. Strictly necessary cookies cannot be disabled through the preference centre as they are required for the platform to operate.

suerte99 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following retention principles apply:

• Active Account Data: Personal data associated with your suerte99 account is retained for the duration of the account and for a period of five (5) years following permanent account closure, in accordance with standard Philippine record-keeping requirements for licensed gaming operators;
• Financial Transaction Records: Transaction records, including deposits, withdrawals, and bet histories, are retained for a minimum of five (5) years from the date of the transaction, in compliance with Anti-Money Laundering Act record-keeping requirements;
• KYC and Verification Documents: Identity verification documents are retained for the period of your account plus five (5) years following closure, or such longer period as may be required by applicable regulation;
• Customer Support Records: Communications with our support team are retained for three (3) years from the date of the last interaction, for dispute resolution and service improvement purposes;
• Marketing Data: Where you have consented to marketing communications, your contact preferences and communications history are retained until you withdraw your consent or request deletion, whichever occurs first.

Upon expiry of the applicable retention period, suerte99 will securely delete or anonymise your personal data in a manner that prevents recovery or identification. Anonymised aggregate data may be retained indefinitely for statistical and analytical purposes.

suerte99 has implemented a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption: All data transmitted between your device and suerte99's servers is protected by Transport Layer Security (TLS) encryption. Sensitive data stored at rest, including passwords and financial identifiers, is protected using strong cryptographic standards;
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. suerte99 employees and contractors are granted access only to the data required to perform their specific job functions, and all access is logged and audited;
• Two-Factor Authentication: suerte99 offers two-factor authentication (2FA) for player accounts to provide an additional layer of protection against unauthorised access;
• Intrusion Detection and Monitoring: suerte99's infrastructure is monitored continuously for security threats, suspicious activity, and attempted breaches. Automated and human-led monitoring systems are in operation around the clock;
• Vulnerability Management: suerte99 conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in the platform before they can be exploited;
• Staff Training: All suerte99 staff with access to personal data receive regular training on data privacy obligations, security best practices, and incident response procedures.

Under the Philippine Data Privacy Act of 2012 and its implementing regulations, you have the following rights as a data subject. suerte99 is committed to facilitating the exercise of all these rights promptly and without undue restriction:

To exercise any of these rights, please contact suerte99's Data Protection Officer using the details provided in Section 13. suerte99 will respond to all verifiable data subject requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days with prior notice to you. suerte99 will not charge a fee for responding to data subject requests unless requests are manifestly unfounded, excessive, or repetitive.

The suerte99 platform is strictly intended for adults aged 21 years and above, consistent with the minimum legal age for casino-style gaming under applicable Philippine regulations. suerte99 does not knowingly collect, process, or retain personal data relating to individuals under the age of 21.

Where suerte99 becomes aware or has reasonable grounds to believe that personal data has been collected from a person under 21 years of age without appropriate parental or guardian consent, suerte99 will take immediate steps to: (a) close the relevant account; (b) void all associated transactions; (c) securely delete all personal data associated with the account; and (d) report the matter to relevant Philippine authorities where required by law.

Parents and guardians who believe that a minor under their care has registered an account on suerte99 are encouraged to contact suerte99 support immediately using the contact details in Section 13 of this Policy.

suerte99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in its data processing practices, changes in applicable Philippine law, or changes in the nature of the suerte99 platform and services. The effective date and last-updated date at the top of this Policy will reflect the most recent version.

Where amendments are material — meaning they substantially affect your privacy rights or the manner in which suerte99 processes your personal data — suerte99 will provide reasonable advance notice of the changes through an in-platform notification, an email to your registered address, or both. For non-material amendments (such as clarifications of existing practices), suerte99 may update the Policy without individual notice.

Your continued use of the suerte99 platform following the publication of an amended Privacy Policy constitutes your acknowledgement of the amended Policy. If you do not agree with the amended Policy, you should discontinue use of the platform and contact suerte99 to close your account.

Previous versions of the suerte99 Privacy Policy are available upon request by contacting the Data Protection Officer using the details in Section 13.

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or have a concern about how suerte99 processes your personal data, please contact suerte99's Data Protection Officer using the following details: